Comments on Draft IT Policy 2023, Govt. of Kerala

https://itpolicy.startupmission.in/it-policy.pdf contains the draft IT policy 2023 of the Govt. of Kerala. Please post comments on the draft policy on this thread.

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The document does not specify a date by which comments should be sent. Worth sending in comments. On a quick read, Kerala has an opportunity to be the FOSS capital of India. FOSS is widespread at the school level. If this is extended to colleges and to targeted efforts that bridge industry’s supply-demand gap it can lead to a win-win situation where industry gets well trained talent, individuals get jobs and Kerala becomes an attractive IT destination. Any volunteers willing to help draft a response?

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The Government of Kerala has come up with the draft of the Kerala IT Policy 2023 and the draft is now being published for obtaining feedback and suggestions from the public.

Those who would like to give suggestions, modifications in the Kerala IT Policy 2023 Draft please submit the same in the below form.

Last date to submit November 16th, 2023

It isn’t mentioned in the document but i went to the “home” URL and the deadline for submissions is mentioned in there. Ref https://itpolicy.startupmission.in/

Personal highlights

The Free and Open-Source Software (FOSS) philosophy adopted by Kerala and promoted under the leadership of the various knowledge societies/communities including IT@School programme (now Kerala Infrastructure and Technology for Education (KITE), and later by International Centre for Free and Open Software (ICFOSS) has resulted in the development of a vibrant FOSS community and widespread adoption of open-source software in critical applications

The State later pursued innovative initiatives such as statewide high-speed giga fiber infrastructure, Kerala Fiber Optic Network (K-Fon Project) which envisions providing high-quality bandwidth connectivity to over 30,000 Government offices and commercial connections to households. The scheme will provide subsidized / free internet connectivity to about 2 million households in the near future realising the State’s declared policy of making the Internet a basic right for every Citizen. KFON will form a key enabler in the next stage of growth of IT in the State by ensuring competition amongst various ISPs and ensuring good internet connection to the Citizens at reasonable costs.

A statewide training infrastructure- Skill Delivery Platform Kerala (SDPK) covering over 100 technical institutions – helps in developing talent in emerging areas of technology with the support of KSITIL & ICT Academy Kerala, a public-private partnership in IT capacity building.

Kerala has been declared as the 1st State to be completely Digital in Education, with over 4.5 Lakh ICT equipment deployed to 16000 schools, under the KITE programme. The Little KITES IT Clubs operational in over 2000 schools are the largest ICT network of students in the Country and has benefitted over 3.75 Lakh students till now. The Little KITES students train their counterparts and to the public as well. KITE VICTERS educational channel which is operational 24/7 was the single source for education for over 4.5 million students during the Covid-19 pandemic and it is a unique model in the State.

2.5 Policy Objectives
16. To encourage community initiatives in the promotion of Free and Open Source software and
hardware
26. To transform Higher Education sector as a hub for FOSS, as a continuation to the similar
activities in school education.

3 Chapter III: e-Governance and Smart Governance
3.1 Introduction
As per IT Policy 2017, the vision of the Government was to establish best-in-class architectural governance, processes and practices with optimal utilization of ICT infrastructure and applications to offer ONE GOVERNMENT experience to all. Major e-governance applications have evolved in silos, organically fueled by the internal push to roll out electronic services to its Citizens resulting in multivendor engagements leading to departments adopting different standards, technologies, architecture and methodologies for delivering e-services. Lack of a Coherent approach, lack of standards and interoperability has become a major stumbling block in achieving the “One Government” vision. Hence it is of paramount importance to set standards/and architectural framework for digital services in the state. Once the framework is set, all further development of apps is to conform to this standard.

The current regime of data management does not enable open sharing of government owned data with other arms of the Government, nor does it expect proactive disclosure of sharable data available with data owners. Such regimes could lead to duplication of efforts and loss of efficiency in planning of activities focused on State development. Efficient sharing of data among data owners and inter and intra-governmental agencies and with public calls for data standards and interoperable systems. Hence, Kerala State Data Policy aims to provide an enabling provision and platform for providing proactive and open access to the data available with various departments/organizations of the Government of Kerala

The Kubernetes-based container platform will be implemented at state data centres as part of modernizing the legacy applications using microservices architecture.

Over the past few years, most of the e-governance applications have been migrated to the cloud. All future e-governance applications must be designed to be platform-independent and accessible to all. Choosing FOSS operating systems and applications can significantly reduce capital and recurring costs for the Government. The policy promotes FOSS technologies for the development and deployment of all e-governance applications. All computers and peripherals being procured in future should be compatible with FOSS. All government departments should encourage the use of FOSS tools on their computers. Research and development institutions as well as higher education institutions are encouraged to explore the possibility of replacing proprietary tools with FOSS alternatives.

5.3.2 Communities
KSUM shall work with the other stake holders of the IT/Industries department to create founder,
maker and opensource communities which will drive an innovation and entrepreneurship
ecosystem in the state of Kerala.

5.3.3.3 Prototyping Labs
…
KSUM will further enhance this digital fabrication infrastructure and create a distributed
prototyping network in the State. To enable this, special focus will be put on Machine Making
projects in Super Fablab to create affordable open-source fabrication machines that can be made
and deployed across the state. These new labs will add to the existing network of Mini Fab Labs
and democratise access to tools for rapid prototyping. KSUM will also create a Design Centre of
Excellence which will provide product design services to startups and also run programs to impart
design skills and provide software and hardware facilities to innovators in the State.

6.3 International Centre for Free and Open-Source Software
ICFOSS is a specialized COE established by ITD in 2009 to evangelize and promote the adoption
of Free and Open Software in the State. IT Policy 2023 envisages transforming ICFOSS as an
international thought leader in the responsible use of new technologies. Even though most of
the technologies that drive the digital revolution are democratized and is easily accessible, the
advanced developments using them still require huge computational resources. ICFOSS will strive
to address this by creating low-cost solutions using open-source hardware and software. In
addition to such developmental efforts, the IT Policy 2023 envisages the following measures to
strengthen the FOSS community in the State through ICFOSS

  1. Special support to develop talent using FOSS technologies in new technology domains like
    AI, Data Analytics, Blockchain, Metaverse etc.
  2. ICFOSS will create a mission to promote the adoption of FOSS software in all scientific
    computations in educational institutions. Replacement of proprietary software like
    AutoCAD, MATLAB, ANSYS, Cadence etc. used in colleges with open-source equivalents
    will be a priority
  3. Support will be provided to ICFOSS to replace proprietary High value (such as ERP, High-
    value scientific software, graphics software) software used in government applications to
    reduce the public spending on software procurement by at least 30% during the next 5
    years. This includes the adoption of FOSS-based ERP, file flow systems, advanced
    computing systems, specialised software etc. ICFOSS will develop programs to develop
    talent to drive this transformation
  4. The FOSS hardware Centre of ICFOSS will be developed as an International Centre of
    Excellence on open hardware.

6.4 ICT Academy Kerala
ICT Academy Kerala (ICTAK), an institution set up through public-private participation is involved
in skill training in various technology domains. IT Policy 2023 envisages to enhance the operation
of ICT Academy during the next 5 years to drive the knowledge revolution in the state. To
strengthen ICT Academy, the following policy support will be provided.

  1. ICTAK will be provided with training infrastructure to train 1 million people in the next 5
    years in various digital technologies so as to create a strong ecosystem of talent from
    Kerala.
  2. ICTAK will synergise the training efforts of various agencies in the State in IT and related
    areas
  3. ICTAK will strengthen the Skill Delivery Platform of Kerala to expand the same to at least
    100 more institutions in the next 5 years.
  4. Support will be provided to ICTAK to create programs to retain the talent within IT
    industries to scale up their growth
  5. Through the Technopark-facilitated IGNITE Program, ICTAK & IT Parks shall support the
    onboarding of interns for Industry; 5K of Internship fee will be contributed by the Kerala
    government
  6. In association with Kerala Knowledge Economy Mission, ICTAK will provide placement
    assistance support to IT companies in the State, thereby reducing the talent onboarding
    time for Companies

6.5 Kerala Infrastructure and Technology for Education (KITE)
…
As part of IT Policy 2023, the following activities are proposed by KITE.

  1. To promote Digital education in tune with the new era by developing new ICT text books for
    Classes 1 to 10, which will include new-age technologies such as Cyber Safety and Digital
    Media Literacy.
  2. To impart specialised training to 25 Lakh students in next 5 years in areas such as Robotics,
    IoT and AI through 60,000 Little KITES IT members through peer-group learning.
  3. To transform Higher Education sector as a hub for FOSS, as a continuation to the similar
    activities in school education
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@sudo_navendu any chance you’re free to comment on this?

My GCPP course is on-going, but I can take up something short and pointed. I scanned through the policy. Some ideas below. @rahulporuri do they also post comments online with attribution ? Looking at 2 points in the GCPP course :smiley: (Thinking of submitting some points that are unrelated to FOSS.)

One contribution we can make is something related to creating an “upload culture” in the government. Governments are looking to become FOSS consumers, and it would be fair to argue that they also need to spend money for maintenance of adopted projects ? @Venkatesh_Hariharan any quick pointers on precedents ? There is value if an Indian government entities name were visible in useful open source projects.

I will scan through the document and see if I can come up with something else relevant.

As this is a FOSS united response, so you’ll be looking to limit this to relevant topics - fair assumption ? See below

–
One of the shortest paragraphs in the policy document hides arguably one of Kerala’s known shortcomings. Good to see this acknowledged though, subtle though the reference is.

4.6.4 Simplification of Labour Laws
Given the unique nature of the IT industry marked by frequent voluntary employee attrition and
transfers outside the state especially in larger IT companies, setting up of a welfare act and funds
for IT /ITES/Electronics/ Hi-Tech companies shall be initiated under IT Department.

Pathanapuram is an interesting place in Kerala. It had one of India’s first Rural IT park wholly owned by Corporate360, a startup. This was adversely impacted by trade unionism.

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The “upload culture” is a good idea. Unfortunately, I don’t think there are too many examples of upload by Indian government agencies.And, in this submission, let us stick to FOSS related items only.

Under 2.3.1.4 Specialised Infrastructure for High Tech Industries: The State can focus on the development of High technology industries in both hardware and software sectors by intending to facilities for IP creation and protection etc. Further under 6.6 Creation of Intellectual Property, the IT policy intends to develop capacity to innovate and to create intellectual properties in various domains of technology.

My observation is that the IT Policy of Govt. of Kerala 2023 makes a general statement/reference on Intellectual Property (IP) without defining what constitutes as IP under the policy. If read plainly, software patents would also come under the IP which the policy is trying to achieve “by intending to facilities for IP creation and protection etc.” Since the subject matter of software patents is uncertain in both legal and policy space, it is recommended to have a clear scope on IP. (so, here we can explain the status of software patents and how it is bad for FOOS and cite some cases showing it is uncertain) we want the definition of “Intellectual Property” to be explained clearly. On one hand, the state can’t say that it adopts philosophy of FOOS and on other hand tries to open door for software patents under the disguise of a general term Intellectual properties.

Hence, I propose that we can suggest that the term intellectual property to be defined clearly in line with the philosophy of FOSS.

Reference: - Richard Stallman’s article on usage of term “Intellectual Property”

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The thrust of this document is to increase the gross IT revenue from Kerala from $4B to $50B in the next few years. While the document goes on to showcase what Kerala has done for promotion of IT, it is woefully short on any introspection of why it lost to “neighbouring states” in IT investment. Ideally it should have had a section from leaders of top IT companies on what would they expect from the state of Kerala to increase their investment in the region.

FOSS is just a side show in this policy document.

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Agree with you, Rushabh that FOSS is just a side show in this document. I find that astonishing given the pioneering work successive governments have done to implement FOSS in Kerala. Typically, policy documents outline what the state will do, and outline its priorities for the next few years. They generally don’t have a, “section from leaders of top IT companies on what would they expect from the state of Kerala to increase their investment in the region,” because that is typically done through consultations convened before the policy is released.

We will start drafting our recommendations and send them to Govt. of Kerala by the 15th. Do let us know if there are any suggestions you would like included in the recommendations.

I can’t think of any recommendations - their stated policy goal is bring more revenue to the state. Not sure how FOSS can help in that. This is related to industrial policy - giving tax breaks, cheap land to large IT firms / VC funded startups.

The comments below were submitted today. I will follow up with the Government of Kerala on this.

On behalf of FOSS United, a non-profit foundation that aims at promoting and strengthening the Free and Open Source Software (FOSS) ecosystem in India, we would like to submit our comments and offer suggestions for improvement. Kerala has India’s most vibrant FOSS community and is a leader in applying FOSS in school education. We believe this is Kerala’s biggest competitive advantage at a time when FOSS technologies occupy 60-90 percent of every organization’s technology stack, with these percentages growing every year.

The policy states in its introduction that “The objective of the IT Policy 2023 will be two-fold. On the one hand, the State has to harness the burgeoning opportunities in IT, Electronics and Space sectors both in terms of production and employment while on the other hand, the State should adopt the technologies in various sectors of the economy to bring in a more equitable inclusive growth. This will hasten the State’s stride towards evolving as a true knowledge society, which UNESCO (2005) defines as an equitable and democratic society where knowledge shall be used for human well-being.”
We believe that FOSS fits in perfectly with these objectives because FOSS is built on the principles of collaboration, community and the shared ownership of knowledge. We believe that the Kerala Government can leverage these principles to carve a unique niche for itself within India’s policy landscape and offer suggestions for the same in subsequent sections.

The introduction recognizes that, “With the emergence of the fourth industrial revolution characterized by the convergence of the digital, physical and biological world, the world is witnessing a digital revolution driven by a host of new technologies like Artificial Intelligence, Data Analytics, Blockchains, Cloud Computing, Quantum computing etc. The key aspect of emergence of these digital technologies is their ubiquitous nature and the pervasive impact they have on multiple sectors of society.” We would like to point out that FOSS is the building block for all these technologies. Therefore, we propose that FOSS be made central to the “Human Resource Development (through Capacity Building programs)” goal that is listed in Section 2.4 New Policy Framework. This can make Kerala a sought after destination for IT companies working in the above mentioned areas.

Section 2.3.1.4 Intellectual Infrastructure

This section, and other sections of this document make general statements on Intellectual Property (IP) without defining what constitutes IP under the policy. If read plainly, software patents would also come under the IP which the policy is trying to achieve “by intending to provide facilities for IP creation and protection etc.” Software Patents are state granted monopolies that are inconsistent with the freedoms to read, modify, and redistribute that are cherished by the FOSS community. As Richard Stallman, the founder of the Free Software Foundation has pointed out, “It has become fashionable to toss copyright, patents, and trademarks—three separate and different entities involving three separate and different sets of laws—plus a dozen other laws into one pot and call it “intellectual property.” The distorting and confusing term did not become common by accident. Companies that gain from the confusion promoted it. The clearest way out of the confusion is to reject the term entirely.” Stallman’s reasoning can be read at Did You Say “Intellectual Property”? It's a Seductive Mirage - GNU Project - Free Software Foundation

We therefore recommend that this policy remove the term “Intellectual Property” and use the specific terms, “copyrights” and “trade secrets” where appropriate. We also recommend that state funds should not be used to incentivise the filing of software patents since this privileges private monopolies, and goes against the FOSS principle of shared ownership of knowledge.

2.3.3 Progress in E-Governance

We appreciate the use of FOSS in KITE (formerly IT@Schools) and in government applications. We recommend that Kerala go one step further and adopt a “Public Money, Public Code” principle whereby the source code of all publicly funded software is hosted on a public repository. We also recommend that the Government of Kerala build vibrant FOSS communities around this public code by encouraging civic participation.

2.5 Policy Objectives

We welcome subsection 15 which aims to, “strengthen the adoption of FOSS-based solutions in all e-Government solutions and to replace at least 30% of high-value software (such as ERP systems, HRMS etc) procured currently through public funds with FOSS software.” We would be happy to work with the Government of Kerala to achieve this objective.

We welcome subsection 26 which aims, “To transform Higher Education sector as a hub for FOSS, as a continuation to the similar activities in school education.” As mentioned earlier, this will help Kerala become a preferred IT destination. FOSS United would be happy explore how we can support the Government of Kerala in this area.

3.3 Smart Governance - Need for a data policy

This section refers to the government as the “owner” of data. We would like to point out that the owners of data created with public money are the citizens and not the government whose role is that of the custodian of this data. We therefore request that the words “government owned data” be replaced with the words, “data in government custody.” This change is not merely a change in terminology but essential for a change in mindset. We hope that all datasets held in government custody are opened up soon so that citizens can study and leverage them to solve their own challenges.

3.6 FOSS Adoption

We welcome the section on FOSS adoption and agree that it can “significantly reduce capital and recurring costs for the government.” To this end, mandating that all future applications are platform independent and accessible to all, and all computers and peripherals procured are compatible with FOSS are necessary but not sufficient conditions. Our observation has been that similar efforts in the past have failed due to lack of investments in change management, training/retraining, capacity building and support. We therefore recommend that GoK invest in change management, training/retraining, capacity building and support.

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